CSPI's comment on updated staple food stocking standards for retailers in SNAP

The Center for Science in the Public Interest (CSPI) submits these comments in response to the USDA Food and Nutrition Service (FNS) request for comments on its proposed rule to update staple food stocking standards for retailers in SNAP.

CSPI supports FNS’s proposal to increase the variety of food options at SNAP retailers by increasing the minimum number of staple food varieties that SNAP retailers must carry from three varieties for each of the four staple food categories (12 total varieties) to seven varieties for each category (28 total varieties).

However, neither the current SNAP retailer staple food stocking standards nor the updated standards in the proposed rule include nutrition standards (e.g., limits on added sugar, sodium, saturated fat, and refined grains) for foods to count towards minimum inventory requirements. At present, the proposed rule represents a missed opportunity to leverage stocking standards towards achieving the goal, as articulated in the Make America Healthy Again (MAHA) Commission’s Make Our Children Healthy Again Strategy Report, of “reorient[ing] the [SNAP] program towards better nutrition.”

In this comment, we provide recommendations on areas of the proposed rule that should be strengthened and we highlight aspects of the proposed rule that should be maintained.

We recommend FNS strengthen the proposal by:
• Including nutrition requirements for foods to align with a healthy dietary pattern
• Treating butter and cooking oils the same so that both are considered accessory foods instead of allowing butter to count toward the minimum number of staple food varieties in the dairy category
• Providing more support for small and independent retailers for implementing the updated standards

We agree with several aspects of FNS’s proposal that support healthy food access, including:
• Adopting a new food staple variety framework that will more than double the number of different staple food items required at SNAP retailers (from 12 to 28 stocking units)
• Continuing to allow a limited number of plant-based alternatives in the dairy group
• Clarifying that pre-cut fruits and vegetables can count towards the fruit and vegetable category requirements
• Adding nuts/seeds and beans, peas, and lentils to count towards the protein category and considering them to be separate varieties
• Adding snack bars, jerky, and cheese/fruit dips and spreads to the list of accessory foods that cannot count as staple foods.